Kendy Knight (Notable Exception)

Two Days Left On This: federalregister.gov/document… Here is the Comment by The IT Contractors Union: The IT Contractors Union is a business league with close to 100 members. It is established to promote the common interests of and improve business conditions for persons working for hire in Specialty Occupations classified as Computer and Mathematical, Installation, Maintenance and Repair, and Production Occupations. The fee in this proposed rule is essential to combat the gross fraud and cheating committed by the H1B staffing industry. In the latest LCA Dataset, 2026 Q3, no less than 9,000 separate “employers” filed LCAs under NAICS Code 541, with a Secondary Entity defined, and a Worksite Address that did not match the Employer Address. These would be the “consultancies” i.e. shell-companies that are perpetrating Visa fraud. Additionally, American companies that act as staffing agencies are likewise committing Visa fraud to profit from the H1B Visa Program. This fraud typically takes the form of: “Ghost” companies, or entirely fake companies. “Ghost” offices, that are never occupied, and are used only as a front. False advertising of company services via the Internet, when the true purpose of the business is to provide personnel. Publishing fake job offers. Listing fake worksite addresses on LCAs Naming Secondary Entities on LCAs when no such business relationship exists. All of this has been sufficiently published via the Free Press to be considered common knowledge. As such the Administration has been given notice of the colossal fraud at hand, and because the Administration has a duty to prosecute that fraud, the Administration must employ personnel to do so. A mandatory part of that enforcement is Worksite visits to each and every worksite employing H1B workers. Because there are no less than 150,000 separate Worksite Addresses in the latest LCA Disclosure Data, (2026 Q3), the Administration must either hire thousands of employees to do this work, or in the alternative offer it to American workers in a manner similar to that used to take the national Census. It is well settled law in America that a permit fee is not a tax, and must be set at the cost of verifying compliance with the permission given. In the case of building and food-service permits it covers the cost of sending inspectors to sites to verify work is being done to established standards of care. A Visa is a permit to enter a country and permission engage in specific conduct while there. Because employers sponsor the H1B Visa, it is the employers that must be billed for the permit fee to cover the cost of inspectors doing site visits. Ultimately, the cost of the fee as stated in the proposed Rule, is wholly justified because Indian scammers have come to America by the thousands, formed phony companies, and imported several million fraudsters from India, by false pretenses, gross fraud and cheating. The cost of prosecuting those persons must be paid for by the companies operated by them, that are used to defraud America via mass exploitation of the H1B Visa Program. Piero Bugoni, Director, IT Contractors Union